NCS000122_Inspection Report UNSIGNED_20190524

RaY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
NORTH CAROLINA
Environmental Quality
May 24, 2019
General Timber, Inc.
Attn. Clement Williams, Owner
625 Farmville Coal Mine Road
Sanford, NC 27330
Subject: Compliance Inspection
Permit No. NCS000122
General Timber, Inc.
Chatham County
Dear Mr. Williams:
On May 15, 2019, Alaina Morman and Lauren Garcia, inspectors with the North
Carolina Department of Environmental Quality (NCDEQ) - Division of Energy, Mineral and
Land Resources (DEMLR), met with Greg Williams, at the facility located at 625 Farmville
Coal Mine Road in Chatham County, to conduct a compliance inspection. The inspection
consisted of reviewing: the Stormwater Pollution Prevention Plan (SWPPP) and each of its
components, the facility's stormwater outfalls, and the overall site conditions. The
inspection was conducted to ensure stormwater best management practices are being
followed, and to help fulfill NCDEQ's goal of inspecting all permitted facilities during each
permit period.
Permit:
This facility has Individual Stormwater Permit NCS000122 to discharge stormwater from
the industrial activity of Wood Preserving [SIC 2491] under the National Pollutant
Discharge Elimination System (NPDES). The permit was originally issued on September 30,
1994 and the current version of the permit was issued on September 1, 2008 and expired
on August 31, 2013.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part II,
Section A of the permit.
• A site map was not included in the SWPPP.
The facility is required to review and update the SWPPP on an annual basis in accordance
with Part II, Section A, Item 7 of the permit. The permittee is also required to amend the
SWPPP when there is a change in design, construction, operation, or maintenance that has
a significant effect of the potential for the discharge of pollutants to surface waters in
accordance with Part II Section A, Item 7 of the permit.
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• There were no records that the SWPPP had been updated since at least 2009.
• The facility has undergone changes in gradient between 2009 and 2019 due to the
mass storage of woodchip/mill in the northeastern section of the site. It was
reported the natural stormwater flow towards outfall 002 was altered and as a
result the facility has not attempted to sample from the outfall since at least 2010.
• During the site visit, a new outfall was observed flowing from the base of the wood
shavings pile towards Georges Creek. Greg Williams was unaware of its presence.
The new outfall has never been identified or sampled by General Timber. Aerial
photographs show the outfall has been visible since at least 2013.
The facility is required to design, install, and monitor a BMP at outfall 001 that has been
shown to remove or reduce copper in stormwater discharges (such as a bioretention cell),
in accordance with Part II, Section A, Item 2.d.
• A copper BMP had not been maintained at Outfall 001 and was not present during
the site visit. DEQ records indicate, from 2011-2014, the chosen BMP consisted of
applying agricultural lime to the soils in the Outfall 001 drainage area. The lime was
expected to raise the pH of the soils, thereby minimizing the mobilization of copper
in stormwater. This BMP was not proven to decrease copper concentrations in the
manner intended by the permit. No records of installation or maintenance of the
copper BMP discussed above, or another copper BMP, exist after 2014. During the
site visit, Greg Williams stated that in recent years the facility placed straw bales
around outfall 001. Straw bales may be considered a good housekeeping measure,
but do not meet the qualifications of the copper BMP outlined in Part I1, Section A,
Item 2.d.
The facility is required to investigate the source of Cu in stormwater discharges from the
facility, in accordance with Part II, Section B, page 6. In addition, the site is required to
continue to make improvements through site modifications and stormwater controls in
order to reduce the Cu in stormwater discharges, as per Part I1, Section A, Item 2.d.
There were no records or indications that the facility has investigated the source of
Cu in stormwater discharges from the facility since at least 2014. Preceding 2014,
the facility claimed the copper exceedances were caused by naturally occurring
copper in the site soils. Agricultural lime was used to address said claim. This BMP
was not proven to decrease copper concentrations in the manner intended by the
permit. No records of investigation or improvements through site modifications and
stormwater controls were available after 2014. Outfall 001 is located in the drainage
basin of a storage yard, where treated creosote and CCA product are stored,
uncovered, for up to 6 months.
Facility Site Review:
This facility operates as a fence post production facility. The facility receives raw wood, the
bark is removed and then poles are cut to size. Either CCA or Creosote are used as
treatments. During the debarking process, chip/mill is a by-product.
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• The 2008 Staff Report states chromium and arsenic were removed from the
monitoring parameters as the facility was planning to transition to a C2 treatment in
place of CCA. The facility did not make this transition and has not been required to
monitor for chromium or arsenic during the current permit term.
Offices are located in a central section of the Property. Chipping/milling occurs in the
northeastern corner of the Property. Wood treatment occurs in buildings located in the
north-northwest corner of the Property. Freshly treated wood is stored on covered drip
pads until wood is dry. Dry, treated wood is stored in storage yards that cover the entire
southern half of the Property, which encompasses at least 10 acres. The wood -treatment
buildings appeared to be well maintained. Bulk storage tanks and process piping in the
wood -treatment buildings were located within secondary containment. Bulk storage tanks
and dispensers for fuel products were located under canopy roofs or within secondary
containment structures.
Chip/mill is stored in large piles in the same area. The chip/mill pile was observed to be
approximately one-story high and covered an area of approximately 0.48 acres. Older
wood, mulch material, and wood scraps are stored in a large pile in the eastern section of
the Property. There is a significant elevation change leading away from the site and
towards the receiving body of water, Georges Creek. The older wood pile extends down the
elevation and appeared to be approximately two -stories high at the back and covers an
area of approximately 1 acre. It is stated in the SWPPP:
"Wood residues, including bark, chips, and sawdust, are managed on -site in a
manner that is intended to lessen impact on stormwater quality. In fact, suspended
solids that are present in the sheet flow from some areas of the facility are filtered
out in the piled wood residues which is beneficial to stormwater quality" -
"Due to their volume and location, the large piles of wood residues serve as a buffer
against the introduction of suspended solids into stormwater that falls directly into
the process area. Fine sawdust and particles become trapped within the piles that
act both as a filter and a sponge during storm events. The locations of the piles are
remote from the major drainage channels and permitted outfalls at the facility."
• While the piles may act as an obstacle for larger wood products, the piles do more
damage to stormwater than good. The wood piles act as large composts. Greg
Williams even stated the temperature of the pile has become so hot in the past that
it caught fire. The decomposing wood produces leachate that is carried directly into
Georges Creek by stormwater. Rain will also infiltrate the piles and the small
particles will be the first to migrate through and out of the pile.
• During the site visit, it was observed that a new outfall had formed at the base of the
chip/mill wood pile. Aerial photographs show this outfall has been visible since at
least 2013. It was very apparent that dust, small wood particulates, and residues are
actively being carried through the channel. A significant amount of product was
observed in the channel, moving towards Georges Creek, for approximately 100-
feet, before vegetation and elevation obscured our view of the outfall.
• It should be noted that the Individual Industrial Stormwater Permit, Permit No.
NCS000122, encompasses the whole facility property and applies to any and all
outfalls onsite. It is the responsibility of the facility to update the SWPPP and
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document the closure of old outfalls and the addition of new outfalls. It is the
responsibility of the facility to implement the conditions of the permit across the
site and at all outfalls. All stormwater discharges must be in accordance with
the conditions of the permit. Any other point source discharge to surface
waters of the state is prohibited unless it is an allowable non-stormwater
discharge or is covered by another permit, authorization, or approval, in
accordance with Part I, Section B, page 1, of the permit. Until the facility
returns to compliance with the conditions of the permit, the product leaving
the site through this new outfall is considered an unpermitted discharge.
There are three sampled outfalls located at the facility. Outfall 001, the facility's main
outfall, is located in the southeastern corner of the site and the 10-acre storage yard drains
to this point. As discussed above, due to reoccurring exceedances of copper, a copper BMP
was required to be installed and maintained at Outfall 001. Outfall 002 was located in the
area that is now occupied by the large chip/mill and older wood piles and has not been
sampled since at least 2010. Outfall 003 is located in the northernmost corner of the
property. Waste lagoons used to be located in the northernmost section of the site;
however, these lagoons have since been filled in and vegetated as part of a corrective action
management unit. The only industrial activity remaining in the area that drains to Outfall
003 is the storage of older abandoned and/or reusable equipment. An additional,
undocumented outfall has formed at the base of the chip/mill and old wood piles.
• Outfall accesses at the site were overgrown and difficult to get to.
• Outfall locations were not clearly identified at the site.
• As stated above, a copper BMP did not exist at Outfall 001. A copper BMP is required
in accordance with Part II, Section A, Item 2.d. of the permit.
• As stated above, it is the responsibility of the facility to update the SWPPP and
document the closure of old outfalls and the addition of new outfalls. It is the
responsibility of the facility to implement the conditions of the permit across the
site and at all outfalls.
Receiving Waters:
Stormwater at the site discharges to Georges Creek, a Class C stream in the Cape Fear River
Basin. Georges Creek is an impaired waters experiencing problems with benthos. During
the site visit, Georges Creek was observed to be a bright red color.
Self -Monitoring Program:
The facility is required to provide qualitative and analytical monitoring data twice
annually. There were several disparities identified during the site visit and through email,
regarding monitoring.
• All outfalls at the site have not been monitored in accordance with the conditions of
the permit.
Hunt Environmental Associates, the attending environmental consultants
contracted by the facility to maintain the conditions of the stormwater permit, is
based out of Lumberton, NC. The physical address of Hunt Environmental Associates
places the firm approximately 1hr 30 mins away from the site. It was explained that
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employees work from a home office located in Holly Springs, NC, at a physical
address that places employees approximately 35 mins away from the site.
• Hunt Environmental Associates performs the following to account for their distance
from the site:
o HEA monitors the weather forecast.
o When a heavy storm event (.3 inches of rain or more) is forecasted, they will
attempt to get a sample as long as the storm event is during General Timbers
normal business hours.
o Based on forecast times for rain to start HEA arrives on -site prior to rain
event beginning.
o In the event of HEA not being able to be at General Timber within the 30
mins, Mr. Greg Williams is trained by HEA on how to collect the stormwater
samples.
o Sample bottles remain on -site at all times to ensure any heavy event is
captured.
Greg Williams stated during the site visit, that Hunt Environmental Associates does
their best to get out to the site within the time requirements outlined in the permit.
During the site visit, it was difficult to quickly determine outfall locations. There was
some question as to their specific locations. They were difficult to get to and were
not highly visible.
Corrective Actions:
• Carefully review the new permit and all associated components. Make sure the
permit and all associated components are properly implemented at the facility.
• Update the SWPPP in accordance with permit requirements. The SWPPP should be
amended whenever there is a change in design, construction, operation, or
maintenance that has a significant effect on the potential for the discharge of
pollutants to surface waters. In accordance with Part I1, Section A, Item 7 of the
permit. The SWPPP shall also be reviewed and updated on an annual basis.
• If the facility is unable to independently determine outfalls at the site, the facility
shall work with a DEQ-DEMLR Regional Office contact to determine outfall
locations. Outfall locations should be updated in the SWPPP and all outfalls must be
maintained under the conditions of the permit. As stated above, it is the
responsibility of the facility to update the SWPPP and document the closure of old
outfalls and the addition of new outfalls. It is the responsibility of the facility to
implement the conditions of the permit across the site and at all outfalls.
• Grab samples shall be collected within the first 30 minutes of discharge. When
physical separation between outfalls prevents collecting all samples within the first
30 minutes, sampling shall begin within the first 30 minutes, and shall continue until
completed. Outfalls shall be clearly marked and numbered. It is recommended that
clear access to the outfalls be maintained as a good housekeeping measure.
• Install a copper BMP at Outfall 001, in accordance with the qualifications of the
copper BMP outlined in Part 1I, Section A, Item 2.d. of the permit.
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The determination from the inspection is the facility is not in compliance with the
conditions of their permit in its entirety. If you have any questions or need additional
information, please contact Lauren Garcia at [phone] or lauren.garcia(@ncdenr.gov.
Sincerely,
Lauren Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental
Quality
Enclosures: Inspection Report cc:
Clement Williams, Owner
Thad Valentine, DEMLR Raleigh Regional Office, [e-mail]
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